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August 11, 2015 U.S. Department ofTransportation Docket Management System 1200 NewJerseyAve, SE Washington, DC 20590 RE: ExemptionRequest Under Section 333 ofthe FAAReform Act and Part 11 ofthe Federal Aviation Regulations Dear Sir or Madam: Pursuantto Section 333 ofthe FAAModernization and Reform Act of2012 (the "ReformAct" or "Section 333"), Subsection (f) of49 U.S.C. § 44701, and 14 C.F.R. Part 11, Cobb Strecker Dunphy & Zimmermann, Inc. ("CSDZ") seeks an exemption from the Federal Aviation Regulations ("FARs") listed below and discussed inAppendix

### A to allow CSDZto operate the Typhoon Q5000+ (Manufacture: Yuneec). CSDZ is an Insurance & Risk Management professional firm that specializes in construction and heavy industrial. CSDZ represents these companies inmany fascists including, without limitation, street & road, heavy infrastructure, education, hospitality, oil & gas, industrial, residential & housing, retail office and corporate headquarters. CSDZ plans to use the "UAS" for aerial imagery, inspection and data collection services to help our clients meettheir safety, insurance and risk management obligations at construction sites & industrial settings across the United States. The information collectedby the "UAS" will help CSDZ and its many clients inspect, monitor and oversee their constructionprojects. This will inturntranslate to improved RiskManagement and more realtime decisions in constructionthat will enhance overall safety and lead to economic efficiencies. The safety and public benefits ofusing the "UAS" in construction and industrial applications are significant. The "UAS"reduces the need to operate manned aircraft in unconventional operations, provide more accurate data in a manner that is more safe, economical and efficient, and with a reduced impact onthe environment. Importantly, use ofthe "UAS" also allows CSDZto limit inspections on construction or industrial settings that must otherwise be accomplished byindividuals, oftentimes involving lifts, ladders, scaffolds and other equipment at a height above the surface. Injuries and fatalities ofconstruction workers performing suchtasks are well-documented. Accordingly, use ofthe "UAS" for these services will result inincreased safety for construction and industrial workers. Operations pursuantto the exemption will be subject to strict operatingrequirements and conditions to ensure the highest level ofsafety. The "UAS"that will be utilized, is the Typhoon Q5000+ which weighs approximately 3.75 pounds (1700 grams). The Typhoon Q5000+ is powered electricallyvia small, lithiumpolymerbatteries that drive electric propellers and operate at a cruising speed ofno more than 8 meters per second. The "UAS" were designed with extensive automated control features, redundant systems, and integrated fail-safes, andthey 1 150 South Fifth Street I Suite 28oo I Minneapolis, MN 55402 I Tel: 612.349.2400 I Fax: 612.349.2490 www.csdz.comcobb strecker dunphy 

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### Exemption Requested
CSDZ respectfullyrequests exemptions from the following regulations: 1 14 C.F.R. Part 21, SubpartH; 14 C.F.R. 

### § 91.7; 14 C.F.R. 

### § 91.9(b)(2); 14 C.F.R. 

### § 91.113; 14 C.F.R. 

### § 61.113(a), (b); 14 C.F.R. § 61.133(a); 14 C.F.R. 

### § 91.119(c); 14 C.F.R. 

### § 91.121; 14 C.F.R. 

### § 91.151; 14 C.F.R. 

### § 91.203; 14 C.F.R. 

### § 91.405(a) and (b); 14 C.F.R. 

### § 91.407(a)(l); 14 C.F.R. 

### § 91.409(a)(l)-(2); and 14 C.F.R. 

### § 91.417(a).



### The Applicable Legal Standard Under Section 333 Grant ofthis exemption application for use ofthe "UAS" inprecision aerial photography, data collection, inspection and monitoring applications will advance the Congressional mandate in Section 333 ofthe Reform Act to accelerate the introduction of"UAS" into the national airspace system ("NAS") ifit canbe accomplished safely. This law directs the Secretary of Transportation to consider whether certain "UAS" may operate safely inthe NAS before completion ofthe rulemaking required under Section 332 ofthe Reform Act. Inmaking this determination, the Secretary is required to determine which types of"UAS" do not create a hazard to users ofthe NAS or the public, orpose a threat to national security in light ofthe following: 0 The "UAS'"s size, weight, speed, and operational capability; 0 Operation ofthe "UAS" in close proximityto airports and populated areas; and 0 Operation ofthe "UAS" within visual line ofsight ofthe operator.

1Asset forth inAppendixB, CSDZwilloperate undersimilaroperatingconditions as those required in the othergrants of exemption, in which exemptions for certainF ARswere deemedbythe FAA as "not necessary."Accordingly, CSDZdoes notrequestFAA exemption from 14 C.F.R 45.23(b), 91.103, and 91.109(a). 

### If the FAA determines thatrelief from these oranyother regulation is required for the operationsproposedherein, CSDZwillbe happyto submitan amendmentto this request andinclude justifications for those necessaryadditionalexemptions. 3 150 South Fifth Street I Suite 2800 I Minneapolis, MN 55402 I Tel: 612.349.2400 I Fax: 612.349.2490 I www.csdz.comcobb strecker dunphy 

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will be operated under controlled conditions and at low altitudes in airspace that is limited in scope. Though the "UAS" may safely be operated byone person, flight operations performed pursuant to this exemption will consist ofat least two people: a pilot-in-command (the "PIC") and visual observer. The PIC is responsible for the direct and safe operation ofthe "UAS", monitoring their status and flight dynamics while maintaining visual line ofsight and keeping the flight within the manufacturer's specified limits interms ofwind, flight range, battery life, and other operating limitations. The observer will be responsible for monitoring the airspace for other aircraft and hazards, advising the PIC before and during flight ofall such observed risks, and monitoring the controlled operating area. Individuals acting as the PIC will complete training specific to the "UAS". The PIC will be a certificated airman who holds either an airline transport, commercial, private, recreational or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver's license issued by a state, the District ofColumbia, Puerto Rico, a territory, possession, or the federal government. Because the "UAS" will be used in lieu ofcomparativelyhigher risk operations now conducted with either fixed wing and rotary manned aircraft orby individuals, the FAA can have confidence that CSDZ's operations will achieve a greater level ofsafety and fulfill the Secretary ofTransportation's responsibilities under Section 333(c) ofthe Reform Actto "establish requirements for the safe operation ofsuch aircraft systems in the national airspace system." Moreover, the FAA has already granted many 333 exemption requests for operation ofthe "UAS" models requested here. [FAA ExemptionNos. 11325; 11351; 11357; 11325, 11327.]. Accordingly, it should grant this exemption request without delay.

Applicant Information The name ofthe applicant is: Cobb Strecker Dunphy & Zimmerman The primary contact for this application is: Scott Staffon, CSP Director ofRisk Management Cobb Strecker Dunphy & Zimmermann 150 South 5th Street, Suite 2800 Minneapolis, MN 55402 Phone: (612) 281-7087 E-mail: sstaffon@csdz.com

2 150 South Fifth Street I Suite 28oo I Minneapolis, MN 55402 I Tel: 612.349.2400 I Fax: 612.349.2490 I www.csdz.comcobb strecker dunphy 

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Reform Act§ 333(a)(l). Ifthe Secretary determines that such vehicles "may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft in the national airspace system." Id §333(c) (emphasis added)? The Federal AviationAct expressly grants the FAA the authorityto issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under §40 1 01 ofthe Act, from the requirement that all civil aircraft must have a current airworthiness certificate and those regulations requiring commercial pilots to operate aircraft in commercial service: The Administrator maygrant an exemption from a requirement of a regulation prescribedunder subsection (a) or (b) of this section or any of sections 44702- 44716 of this title if the Administrator finds the exemption is in thepublic interest. 49 U.S.C. §44701(f). See also 49 USC §44711(a); 49 USC §44704. The grant ofthe requested exemption is inthe public interest based on the clear direction in Section 333 ofthe Reform Act; the additional authority in the Federal Aviation Act, as amended; the strong equivalent level ofsafety surrounding the proposed operations; and the significant public benefit, including enhanced safety and cost savings associated with transitioning to "UAS" for aerial imagery, data collection and inspection services. CSDZ therefore respectfully requests that the FAA grant the requested exemption without delay.
Airworthiness ofthe Typhoon 

### 0 500 One element ofthe exemption application involves evidence ofthe airworthiness ofthe "UAS". CSDZ believes that the "UAS" have been shownto be airworthy and compliant with a significant level ofsafety. The manyprevious 333 Grants ofExemptions bythe FAA further highlight that operations ofthe "UAS" will not adversely affect safety when comparedto similar operations conducted by aircraft that have been issued an airworthiness certificate under 14 C.P.R. Part 21, Subpart H. [E.g., FAA ExemptionNos. 11357, 11325.]

2 Thisprovisionplaces a duty on theAdministratorto notonlyprocessapplications for exemptions under Section 333, but for theAdministrator, 

### if he deems the conditionsproposedherein to require modification in order to allow approval, to supply conditions tor the safe operation o[the "UAS". CSDZwelcomes the opportunityto consultwith FAA staff to address any issues or concerns that this proposalmay raise thatFAA staff believes may require modification.
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To enhance safety, it is also importantto note that the "UAS" are equipped with automated features which enhance safe takeoff, flight, and landing in many conditions, further details of which are provided inthe applicable Q5000+ User Manuals.3 To maintain airworthiness, CSDZ will follow the inspection and maintenance programs designed specifically for the "UAS" bythe manufacturer, Yuneec Electric Aviation. Those programs are enhanced by an inflight monitoring system for the "UAS"that monitor current position, wind speed and direction, battery charge, flight time, and altitude, including both above the takeoff location and above sea level. Ifonboard sensors detect a critical situation at any time (low battery, close proximityto the ground, weak data link signal, etc.) the "UAS" will automatically initiate a preprogrammed safetyprocedure. In the event ofany malfunction, the "UAS" will undergo all maintenance required bythe manufacturer and undergo flight testing before recommencing commercial operations.

Proposed Operation and Associated Conditions CSDZ intends to use the "UAS" that weigh significantly less than 55 pounds for the purpose ofcollecting aerial photography and data, as well as aerial inspection and monitoring applications at construction and industrial sites. All ofthe "UAS" operations will occur under tightly controlled conditions on privately owned land at the owner's request and consent, solely during daylight hours, and at altitudes well belowthat which wouldpose a risk to other aircraft. The operations will take place in areas away from people, crowds and airports. Moreover, due to the nature and purpose ofthe operations, CSDZ will fly the "UAS" at relatively low altitudes and speeds. The risk of interference with another aircraft is therefore minimal.
Grant ofthis exemption to CSDZ will be subject to the conditions listed inAppendixB which are based upon the operating conditions required bythe FAA's previous grants ofexemptions. The "UAS" are characterized by a high degree ofpre-programmed control and various built-in technical capabilities that limit the potential for operation outside ofthe conditions set forth in AppendixB. They were also designed with internal functional and safety features to assist the operator in safe and reliable operation. With pre-programmed flights and manual control, operators can easily maintain separation from manned aircraft operations and avoid other hazards. In the controlled environment under the operations conditions inAppendixB, operations will remain within visual line-of-sight (VLOS) and below 400 feet AGL. In addition, CSDZ will obtain a Certificate ofWaiver or Authorization from the FAA Air Traffic Organization to address airspace requirements and provide notificationby aNotice to Airman (NOTAM).

3 CSDZ canprovide 

### if requestedby the FAA, thefollowing documents, asproprietaryandunder corifidentiality, in supportof this exemption request: the Typhoon Q5000+ Safety Guidelines, User Manual, QuickStart Guide, MaintenanceManual, FlightBatterySafety Guidelines 5 150 South Fifth Street I Suite 28oo I Minneapolis, MN 55402 I Tel: 612.349.2400 I Fax: 612.349.2490 i www.csdz.com

### cobb strecker dunphy & 

### zimmermann

Operator Requirements
As a conditionto the grant ofthe exemptions, CSDZ will require that the PIC hold either an airline transport, commercial, private, recreational or sport pilot certificate. The PIC must also hold a current FAA airman medical certificate or a valid U.S. driver's license issued by a state, the District ofColumbia, Puerto Rico, a territory, possession, orthe federal government. The PIC will also be subject to the flight review requirements pursuantto the Federal Aviation Regulations ("FARs"). In addition, the PIC must complete a FLYSAFE training program. This training familiarizes the PIC to the operations and limitations ofthe "UAS". Training will also include discussions on the basic fundamentals of"UAS" aerodynamics and technical limitations, as well as the more general topics ofweather, the National Airspace System, and the regulatory framework. CSDZ does not believe that certified airmen, medical certificates, and the related operating conditions, are necessary or required to operate the "UAS". However, CSDZ will accept these requirements as a condition to the grant ofthis exemption. If, and when, the FAA finds such conditions unnecessary for operations conducted pursuant to Section 333 exemptions, CSDZ respectfully reserves the right to amend its operating conditions and request exemption from the relevant FARs to operate without such conditions. Public Interest The use ofthe "UAS" in lieu ofcomparativelyhazardous operations currently conducted with conventional fixed wing and rotary aircraft offers a net safetybenefit and will achieve an enhanced level ofsafety, as mandated under Section 333(c) ofthe Reform Act. Approval ofthis application will also benefit the public interest by allowing better, safer, and more cost efficient information for CSDZ and the public. Moreover, it will lessen the need for inspections by individuals that must often use equipment to observe construction sites from heights above the surface. Conventional aerial photography, inspection and monitoring operations using manned aircraft involve heavy aerial aircraft that must transit from airports to the operational location, carrying significant amounts ofcombustible fuel, and a multi-person crew. Manned aircraft are also at risk offuel spillage and fire inthe event ofan accident or incident. Bycontrast, use ofthe "UAS" is safe, economical and efficient. The Typhoon Q5000+ weights approximately 3.75 pounds and is carried (not flown) to and from the area ofactivity, which poses much less risk to people and infrastructure onthe ground, as well as other aircraft. No national security issue is raised bythe grant ofthe requested exemptions. Given the size, load-carrying capacity, the speed at whichthe "UAS" operates (8 meters per second), and the fact that they do not carry explosives or other dangerous materials, the use ofthe "UAS"pose no threat to national security. Infact, the threat ofcausing damage to property is significantly reduced with the extremelylow weight ofthe "UAS" and limited operating areas. Any other

6 150 South Fifth Street I Suite 28oo I Minneapolis, MN 55402 I Tel: 612.349.2400 I Fax: 612.349.2490 ! www.csdz.comcobb strecker dunphy & zimmermann

Any other security concerns are ameliorated bythe fact that all individuals holding an FAA airman certificate are subject to a security screening bythe U.S. Department ofHomeland Security, 49 U.S.C. §44903G)(2)(D)(i). The grant ofthe requested exemption is in the public interest based on the clear direction in Section 333, the Federal Aviation Act,4 the high and equivalent level ofsafety ofthe proposed operations, and the significantpublic benefit, including enhanced safety and cost savings to be realized as a result ofthe use ofthe "UAS" for aerial imagery, data collection and inspections. It is also in-line with the previous Grants ofExemption by the FAA for the same and similar "UAS" models and manufacturers. [FAA Exemption Nos. 11357, 11325, 11327.] Accordingly, CSDZ respectfully requests that the FAA grant an expedited exemption.
Very truly yours,

4 The FederalAviationActexpresslygrants the FAA the authority to issue exemptions: The Administratormaygrantan exemption from a requirement of a regulationprescribedunder subsection (a) or (b) of this section or any of sections 44702-44716 of this title 

### if theAdministrator finds the exemption is in thepublic interest. 49 U.S. C.§44701(f).
7 150 South Fifth Street I Suite 2800 I Minneapolis, MN 55402 I Tel: 612.349.2400 I Fax: 612.349.2490 www.csdz.comcobb strecker dunphy & zimmermann


### Appendix A Exemption Request and Equivalent Level of Safety Showings UnderApplicable Rules Subject to Exemption 

### 14 CFRPart 21, Subpart H: Airworthiness Certificates 14 CFR § 

### 91.203 (a)(1)

Section 91.203(a)(l) requires all civil aircraft to have a certificate ofairworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance ofairworthiness certificates as required by FAR§ 91.203(a)(1). Giventhe very small size ofthe aircraft andthe limited operating area associated withtheirutilization, it is unnecessaryto go throughthe certificate ofairworthiness process under Part 21 Subpart H to achieve orexceed current safetylevels.5 Suchan exemptionmeets the requirements ofan equivalent level ofsafetyunder Part 11 and Section 333 ofthe Reform Act. The Federal AviationAct and Section 333 ofthe Reform Act both authorize the FAAto exempt aircraft from the requirement for an airworthiness certificate, upon consideration ofthe size, weight, speed, operational capability, and proximity to airports and populated areas ofthe "UAS" involved. In this case, ananalysis ofthese criteria demonstrates that the "UAS" operated without an airworthiness certificate, under the conditions proposedherein, will be at least as safe, or safer, than a conventional aircraft (fixed wing orrotorcraft) with an airworthiness certificate. The Typhoon Q5000+ weighs approximately2.7 pounds. The Typhoon Q5000+ does not carry a pilot orpassenger; it does not carry flammable fuel, and will operate exclusively within an areapre-disclosed and in compliance with conditions set forth herein. Operations underthis exemption will be tightly controlled and monitored bythe operator, pursuantto the conditions set forth inAppendix B, the applicable Q5000+ manuals, the CSDZ "UAS" General Operations Manual ("GOM"), and by local public safetyrequirements. The FAA will have advance notice ofall operations throughthe filing ofNOTAMs. Receipt ofthe priorpermission ofthe land owner (or lessee), the size ofthe aircraft, the lack of flammable fuel, and the fact that the aircraft is carried to the location and not flown there all establishthe equivalent level ofsafety. The "UAS" provide at least an equivalent level of safetyto that ofsuch operations conducted with conventional manned aircraft that would be

5 The FAA has statedthatno exemption is needed from this section if a

finding is made under the Reform Actthat the "UAS"provide an equivalentlevel of safetywhen comparedto aircrqftnormally used for the same application. These criteriaare satisfiedandtherefore no exemption·is needed [See e.g., Exemption No. 11220 (an exemption from 91.203 notrequiredfor the Phantom).]However, CSDZrequestsan exemption in the eventthat the FAA determines thatsome characteristicsof the "UAS"failto meetthe requirements of the ReformAct. 8 150 South Fifth Street I Suite 2800 I Minneapolis, MN 55402 I Tel: 612.349.2400 I Fax: 612.349.2490 I www.csdz.comcobb strecker dunphy 

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### orders-of-magnitude larger and would be carrying passengers, cargo, and flammable fuel. The safety features including the redundant sensor systems, as described in the DJI User Manuals, and throughout this document, underscore the importance placed on safety and reliability in the design and manufacture ofthe "UAS".

14 CFR § 91.7 (a)- (b); Civil Aircraft Worthiness 

### Section 91.7(a) requires that a civil aircraft must be in airworthy condition to be operated. In previous grants ofexemption for the "UAS", the FAA concluded that an exemption was required under 14 C.P.R.§ 91.7(a). In each instance, the FAA granted reliefunder§ 91.7(a) through a requirement that each petitioner ensure that the "UAS" is in an airworthy condition- based on compliance with the User Manual- prior to every flight. [See e.g., Exemption No. 11220, p. 5.] CSDZ therefore requests that the FAA find similar reliefunder the same conditions here. Section 91.7(b) places responsibility on the PIC to ensure an aircraft is in a condition safe for flight. In 

### prior grants ofexemption to the "UAS", the FAA determined that exemption from this section was not necessary. [See e.g., Exemption No. 11191; 11195; 11120.] To the extent that the FAA determines an exemption is required here, CSDZ respectfully requests that the FAA find compliance with the manufacturer's manuals, and requirements ofthe grant ofexemption, a sufficient means for ensuring that the "UAS" are in a condition for safe flight.

14 CFR § 91.113 Right-of-Way Rules 

### Section 91.113 requires that vigilance be maintained by each person operating an aircraft to see and avoid other aircraft. Unlike manned aircraft, the "UAS" pilot is not on-board the aircraft to observe and avoid other aircraft, operating the "UAS" from the ground. CSDZ's proposed operating conditions will achieve an equivalent or greater level of safety. All operations will involve two individuals-one FAA certificated pilot as the PIC and one visual observer who will monitor the immediate and surrounding airspace of the operation for potential obstruction hazards and other possible intrusions. The "UAS" will also be limited to designated areas below 400 feet AGL and within a virtual fence. CSDZ will notify the FAA and other pilots ofthe "UAS" operations byNOTAM.

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### 14 CFR 

### § 61.113(a) & 

### (b); 61.133 (a): PrivatePilotPrivileges and Limitations; Pilot in Command; CommercialPilot Privileges and Limitations Section 61.113(a) & (b) limitprivate pilots to non-commercial operations. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the "UAS" are remotely controlled with no passengers orproperty ofothers on-board. Section 61.133(a) requires an individual with at least a commercial pilot's license to act as pilot in command ofan aircraft for compensation or hire. CSDZ respectfullyproposes that operatorrequirements should take into account the characteristics ofthe particular "UAS". Here, the "UAS"have a high degree ofpreprogrammed control and various built-intechnical capabilities that strictly limitthe potential for operation outside ofthe operating conditions set forth in

### AppendixBandthe exemption application. The small size, endurance, range and payload capacities ofthe "UAS"meanthat no passengers and/or cargo will everbe carriedbythe aircraft. Rather, commercial operations will be strictly limited to acquiring aerial imagery, data collection and inspections. Considering these conditions, operating limitations and restrictions, an equivalent level of safety will be provided by allowing operation ofthe "UAS" by CSDZ with individuals who possess a valid FAA airline transport, commercial, private, recreational or sportpilot certificate. The risks associated with the operation ofthe "UAS" (given their small size, speed, operational capabilities and limitations, and lack ofcombustible fuel) are so diminished from the level ofrisk associated with commercial operations (and even operations permitted with a private pilot certificate) contemplated byPart 61 with manned aircraft, that allowing operations ofthe "UAS" as set forth in

### AppendixB meets and exceeds the present level ofsafetyprovided under 14 C.F.R. § 61.113(a)-(b), and does not call for a commercial pilot certificate as set forth in§ 61.133. [FAA ExemptionNo. 11357 (requiring at least a recreational or sportpilot certificate, and a current FAA airman medical certificate orvalid U.S. driver's license).] 

### 14 CFR 

### § 91.119: Minimum SafeAltitudes Section 91.119 establishes safe altitudes for operation ofcivil aircraft. Specifically, 91.119(c) limits aircraft flying over areas otherthan congested areas to an altitude of500 feet above the surface, except over openwater or sparselypopulated areas. In those cases, the aircraft may not be operated closerthan 500 feet to anyperson, vessel, vehicle, or structure. As set forth herein, the "UAS" will not operate at higherthan 400 feet AGL. The "UAS" will, however, be operatedto avoid congested orpopulated areas. Because aerial photography, data collection and inspection work must be accomplished at relatively low altitudes and at altitudes less than 500 feet AGL, an exemption from Section 91.119(c) is needed. The equivalent level ofsafety will be achieved given the size, weight, speed, and material with which the "UAS" are built. Also, all flights will be conducted overprivate and/or controlled

### to
150 South Fifth Street I Suite 28oo I Minneapolis, MN 55402 I Tel: 612.349.2400 I Fax: 612.349.2490 I www.csdz.comcobb strecker dunphy 

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access property withthe permission ofthe land owner orthose who control the land. Because ofthe advance notice to the landowner, all affected individuals will be aware ofthe flights. Comparedto operations conducted with aircraft orrotorcraft weighing far more thanthe "UAS", and carrying flammable fuel, anyrisk associated withthese operations will be significantlyless thanthose currently allowed with conventional aircraft operating at or below 500 feet AGL. Indeed, the low-altitude operations ofthe "UAS" will maintain separation from operations ofconventional aircraft that must complywith Section 91.119. 14 CFR § 91.151 (a): Fuel Requirements for Flight in VFR Conditions This regulation prohibits an individual from beginning "aflight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point ofintended landing and, assuming normal cruising speed

- (1) Duringthe day, to fly after thatfor at least 30 minutes; or (2) Atnight, to fly after that for at least 45 minutes." The Typhoon Q5000+ is powered by a removable, rechargeable, lithium-polymerbatterythat provides approximately20 minutes ofpowered flight. Without an exemption from 

### § 14 CFR 91.151, flights by CSDZ would not be possible. Given the limitations onthe proposed operations and their locations, a less burdensome reserve requirement for flight in daylight VFR conditions is reasonable. Moreover, Typhoon Q5000+provides lowbattery warnings that indicate the PIC must command the aircraft's return to the launchpointwhen lowbattery capacityvoltage is reached. A critical lowbattery warning is also provided. The aircraft will initiate an automatic descent and landing at the critical lowbatterywarning. An exemption from 14 CFR 

### § 91.151(a) is safe andwithin the scope ofthe prior exemptions for the "UAS". [See e.g., ExemptionNo. 11195; 11191.] Inline withthe previous grants of exemption, CSDZ requests thatthe FAA grant reliefunder the condition thatthe PIC will not begin a flight unless (considering wind and forecast weather conditions) there is enoughpower to fly to the first point ofintended landing and, assuming normal cruise speed, landthe "UAS" and to operate after that for at least 5 minutes. [SeeExemptionNo. 11325.]

14 CFR §§ 91.9 (b)(2); 91.203 (a)- (b); Carriage ofCivil Aircraft Airworthiness Certificate and Registration Sections 91.9(b) and 91.203(a)-(b) require an aircraft operatorto carry airworthiness documents and other aircraft manuals onboardthe aircraft at all times. Because the "UAS" are small in size and do not contain a cabin orflight deck, carriage ofsuch documents and manuals is impossible. The intent ofthese regulations is to ensure thatthe PIC has access to important documents during flight. Here, an equivalent level ofsafetyis achieved ifthe PIC has access to the applicable "UAS"manual(s), registration certificate and other required documents from the Ground Control Station from whichhe or she is conducting operations. This is consistent 11 150 South Fifth Street I Suite 2800 I Minneapolis, MN 55402 I Tel: 612.349.2400 i Fax: 612.349.2490 I www.csdz.comcobb strecker dunphy 

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with a prior opinion ofthe FAA Office ofthe ChiefCounsel, and other grants ofexemptions for commercial "UAS" operations. [SeeMemorandum from Mark Bury, FAA Assistant ChiefCounsel for International Law, Legislation and Regulation, to John Duncan, FAA Flight Standards Service (Aug. 8, 2014).] 14 CFR § 91.121: Altimeter Settings Section 91.121 requires that each individual operating an aircraft shall maintain the cruising altitude or flight level ofthat aircraft, as the case maybe, byreference to an altimeter that is set, when operatingbelow 18,000 feet MSL to:

• The currentreported altimeter setting ofa station along the route and within 1 00 nautical miles ofthe aircraft; • Ifthere is no station withinthe areaprescribed inparagraph (a)(1)(i) ofthis section, the currentreported altimeter setting ofan appropriate available station; • Inthe case ofan aircraft not equipped with a radio, the elevation ofthe departure airport or an appropriate altimeter setting available before departure. To provide an equivalent level ofsafety, the "UAS" autopilot calculates the reference altitude (ground level) with on-board GPS. The altitude information generated from the GPS is transmitted to the PIC. The PIC shall confirm the altitude ofthe launch site shown onthe GPS altitude indicator before flight. The FAA has grantedrelieffrom this section in prior grants ofexemptionunderthe conditionthatthe operator set the altimeterto zero feet AGL rather than local barometric pressure or field altitude before each flight. [Exemption Nos. 11062 and 11067.] A similar grant ofexemption is thus warranted here.

14 CFR §§ 91.405 (a); 407 (a)(1); 417 (a): Maintenance Inspections Section 91.405(a) requires that an aircraft operator or owner "shall have that aircraft inspected as prescribed in subpart E ofthis part and shall betweenrequired inspections, except as provided inparagraph (c) ofthis section, have discrepancies repaired as prescribed inpart 4 3 of this chapter

...." Section 91.407 similarly makes reference to requirements in Part 43; Section 91.409(a)(2) requires an annual inspection for the issuance ofan airworthiness certificate. Section 91.417(a) requires the owner or operatorto keep records showing certain maintenance work thathas been accomplished by certificated mechanics, under Part 43, or licensedpilots and records ofapproval ofthe aircraft for returnto service. An equivalent level ofsafety will be achievedbecause the "UAS" are small in size, will solely operate inlimited and predetermined areas, and are not large, complex mechanical machines. CSDZ will perform all maintenance and inspections in accordance withthe manufacturers' manuals and anyrequired manufacturer Safety or Service Bulletins. In addition, the PIC will conduct a pre-flight inspection ofthe "UAS" and all associated equipmentto account for all discrepancies and/or inoperable components. Maintenance will 12 150 South Fifth Street I Suite 28oo I Minneapolis, MN 5·5402 I Tel: 612.349.2400 I Fax: 612.349.2490 I www.csdz.comcobb strecker dunphy & zimmermann

be performed and verified to address any conditions potentially affecting safe operation of the "UAS" and no flights will occurunless and until all flight critical components ofthe "UAS" have been found to be in a condition for safe operation. A functional flight test will be conducted following the replacement ofany flight-critical components.

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### AppendixB CSDZ Operating Restrictions and Limitations 1) Operations authorized bythis grant ofexemption are limited to the Typhoon Q5000+, which weighs approximately 2.7 pounds. Proposed operations ofany other aircraft will require a newpetition or a petitionto amend this grant. 2) The "UAS" shall not be flown at a ground speed exceeding 87 knots (100 miles perhour). 3) Above Ground Level ("AGL") altitude shall be restricted to 400 feet. All altitudes reported to Air Traffic Control ("ATC") shall be in feet AGL. 4) The "UAS" shall be operated within Visual Line-of-Sight ("VLOS") ofthe pilotin- command ("PIC") and visual observer at all times. The PIC must use human vision unaided by any device otherthan corrective lenses, as specified onthe PIC's FAA- issued medical certificate. 5) All operations must utilize a visual observer ("VO"). The VO maybe used to satisfythe VLOS requirement as long as the PIC maintains VLOS capability. The VO and PIC must be able to communicate verbally at all times. The PIC must be designated before the flight and cannot transferhis orher designation for the duration ofthe flight. 6) Any and all additional requirements identified inthe exemption grant bythe FAA shall be added to the "UAS" General Operations Manual ("GOM"). The GOM mustbe maintained and made available to the Administrator upon request. Ifa discrepancy exists betweenthe conditions and limitations inthe granted exemptions and the GOM, the conditions and limitations in the granted exemptions shall take precedence and mustbe followed. Otherwise, the operator must follow the procedures outlined in the GOM. The operator mayupdate orrevise its GOM. Itis the operator's responsibilityto track suchrevisions and presentupdated and revised documents to the Administrator upon the request. The operator must also present updated and revised documents ifitpetitions for an extension or amendment ofthe granted exemptions. Ifthe operator determines that anyupdate or revision would affect the basis upon which the FAA granted the exemptions, then the operator mustpetition for amendment to its exemptions. The FAA's "UAS" Integration Office (AFS-80) maybe contacted ifquestions arise regarding updates or revisions to the GOM. 7) Priorto each flight the PIC must inspect the "UAS"to confirm that it is in a condition for safe flight. The preflight inspection shall account for all discrepancies (i.e., inoperable components, items, or equipment). The PIC shall not operate the aircraft if the inspectionreveals a conditionthat affects the safe operation ofthe "UAS" until the necessarymaintenance has beenperformed and the "UAS" is found to be in a condition

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for safe flight. The Ground Control Station ("GCS") shall be included in the preflight inspection. 8) Any "UAS" that has undergone maintenance or alterations that affect the "UAS" operation or flight characteristics (e. g., replacement ofa flight critical component) must undergo a functional test flight. The PIC who conducts the functional test flight must make an entryinthe "UAS" aircraft records. 9) CSDZ must follow the manufacturer's aircraft/component maintenance, overhaul, replacement, inspection, and life limit requirements. 1

0) CSDZ shall carry out its maintenance, inspections, and record keeping requirements, in accordance with the manufacturer's manuals and instructions. Maintenance, inspection, and alterations must be noted inthe aircraft records, including total flight hours, description ofwork accomplished, and the signature ofthe authorized PIC ortechnician returning the "UAS" to service. 11) The PIC must make a record entry in the aircraft records ofthe corrective action taken against discrepancies discovered between inspections. 12) The PIC must possess either an airline transport, commercial, private, recreational or sportpilot certificate. The PIC must also hold a current

### P AA airman medical certificate or a valid U.S. driver's license issuedby a state, the District ofColumbia, Puerto Rico, a territory, a possession, orthe federal government. The PIC must also meet the flight reviewrequirements specified in 14 C.P.R.§ 61.56 in an aircraft in which the PIC is rated onhis orherpilot certificate. 13) CSDZ will not permit any PIC to operate the "UAS" unless and until that PIC demonstrates the abilityto safely operate the "UAS" in a manner consistent with howthe "UAS"will be operatedpursuantto this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. PIC qualification flight hours and currencymust be logged in a manner consistent with 14 C.P.R. § 61.51(b). 14) The "UAS" shall not be operated directly over anyperson, except authorized and consenting individuals, orbelow an altitude that is hazardous to persons or property on the surface in the event ofan "UAS" failure or emergency. 15) Operating ofthe "UAS" maybe conducted at distances less than 500 feet from participatingpersons, vessels, vehicles or structures thatperform an essential function in connectionwiththese special purpose operations. Operations closerthan 500 feet from the PIC, visual observer, operatortrainees, and essential persons, are permitted when operationallynecessary; butnever so close as to present anundue hazard, per§ 91.119(a).

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16) Operation ofthe "UAS" mustbe conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. the aircraft is operated near vessels, vehicles or structures where the land owner/controller has granted permission and the PIC has made a safety assessment ofthe risk ofoperating closer to those objects and determined that it does not present anundue hazard. 17) Ifthe "UAS" loses communications or loses its GPS signal, the "UAS" must return to a pre-determined location within the operational area and land or be recovered in accordance with the manufacturer's user manuals. 18) The PIC must abort the flight in the event ofunpredicted obstacles or emergencies. 19) The PIC is prohibited from beginning a "UAS" flight unless (considering wind and forecast weather conditions) there is enoughpowerto fly to the intendedpoint of landing and, assuming normal cruising speed, operate after that for at least 5 minutes. 20) CSDZ shall obtain an Air Traffic Organization (ATO) issued Certificate ofWaiver of Authorization (COA) priorto conducting any operation. This COA will also require the filing ofthe NOT AM not more than 72 hours in advance, but not less than 48 hours prior to the operation. 21) All aircraft operated in accordance with the requested exemption mustbe identified by serial number, registered in accordance with 14 C.F.R. Part 47, and have identification (N-Number) markings in accordance with 14 C.F.R. Part 45, Subpart C. Markings shall be as large as practicable. 22) Each "UAS"must comply with all manufacturer System and Safety Bulletins. 23) The radio frequency spectrum used for operation and control of the "UAS" must comply with Federal Communication (FCC) or other appropriate government oversight agency requirements. 24) The documents required under 14 C.F.R. §§ 91.9 and 91.203 shall be available to the operator at the Ground Control Station ofthe "UAS" any time the aircraft is operating. These documents must be made available to the Administrator or anylaw enforcement official upon request.6

. 6 This is consistentwithan FAA Office of Chief Counsel Opinion, datedAugust8, 2014, and preparedby DeanE. Griffith, AGC-220, in which itwas acknowledgedthatthe intentof 14 C.F.R. § 91.9(b) and 91.203(a), (b) is met

### if the PICof the "UAS" has access to the aircraft flight manual, registration certificate, andother requireddocuments from the groundcontrolstation from which he orshe is operating the "UAS". Memorandum fromMarkBury, FAAAssistantChief Counsel forInternationalLaw, Legislation andRegulation, to John Duncan, FAA FlightStandards Service (Aug. 8, 2014).
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25) The "UAS" must remain clear and yield the right ofwayto all other manned operations and activities at all times (including, without limitation, ultralight vehicles, parachute activities, parasailing activities, hang gliders, etc.). 26) Operations shall occur under Visual Meteorological Conditions (VMC); flights under special visual flight rules (SVFR) shall not be conducted. 27) The s "UAS" shall not be operated from any moving device or vehicle. 28) The "UAS" shall not be operated closer than 500 feet below or 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 29) Operations shall not occur in congested or densely populated areas. The "UAS" may not operate in Class B, C, D orE airspace without written approval from the controlling authority. Operations will not be conducted within a 5 NM range ofthe geographic center ofan airport as denoted on a current FAA-published aeronautical chart unless permission has been obtained from the local control tower or, inthe case ofa non- towered airport, written notice has beenprovided to the airport's management, and the operation is conducted in accordance with a NOT AM as required bythe grant ofthis exemption. 30) All operations shall be conducted overprivate and/or controlled-access property with permission from the landowner/controller or authorized representative. Permission from the landowner, controller, manager or authorized representative will be obtained for each flight to be conducted. 31) Any incident, accident, or flight operationthat transgresses the lateral or vertical boundaries ofthe operational area as defined bythe applicable COA shall be reported to the FAA's "UAS" Integration Office (AFS-80) within 24 hours. Accidents shall be reported to the National Transportation SafetyBoard (NTSB) perinstructions contained onthe NTSB Web site: www.ntsb.gov. 32) "UAS" operationsmaynot be conducted during night, as defined by 14 C.P.R. § 1.1.

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Appendix C Federal Registry Summary
Pursuantto 14 C.F.R. Part 11, CSDZ offers the following summary for publication in the Federal Register, shouldpublication be necessary: CSDZ seeks an exemption from the following rules: 14 C.F.R. Part 21, Subpart H; 14 C.F.R. 

### § 91.7; 14 C.F.R. 

### § 91.9(b)(2); 14 C.F.R. § 91.113; 14 C.F.R. § 61.113(a)-(b); 14 C.F.R. § 61.133(a); 14 C.F.R. § 91.119(c); 14 C.F.R. § 91.121; 14 C.F.R. § 91.151; 14 C.F.R. § 91.203; 14 C.F.R. § 91.405(a)-(b); 14 C.F.R. § 91.407(a)(l); 14 C.F.R. § 91.409(a)(1)-(2); and, 14 C.F.R. § 91.417(a). Approval ofthese exemptions will permit CSDZ to conduct commercial unmanned aircraft systems ("UAS") operations in construction and industrial applications for our clients. The exemptions will enhance safetybyreducing risk to the general public and property owners from the risk and hazards associated withperforming equivalent work through individual construction workers and conventional manned aircraft.

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